Frank and Virginia Muhich - Page 6

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sequence of transactions. These materials touted the tax
deductibility of all of the transferring individual's personal
expenses. The materials generally claimed that the individual
would pay no tax on his or her income. The materials made no
mention of any nontax benefit to be gained from the trust scheme.
After meeting with Myers, the Muhichs traveled over 100
miles to the offices of Heritage. There they met with Edward
Bartoli (Bartoli), an attorney who was the principal promoter of
Heritage's scheme. Bartoli introduced petitioner to James Savino
(Savino), a certified public accountant associated with Heritage.
At or about the time of this meeting, the Muhichs submitted to
Heritage a form containing their financial information and
assets. On this form, they stated that their number one
objective was "tax avoidance".
Creation of the Five Trusts
In May 1994, very soon after meeting with Bartoli, the
Muhichs, without consulting the Martins, implemented the multi-
trust scheme to avoid taxes. Petitioner caused Midwest to pay
$12,000 to Heritage, and Heritage supplied petitioners with a
comprehensive packet of forms and documents that could be
customized to create and operate the trust scheme.
Petitioners used the promotional materials presented by Myers as
a model for their trust arrangement.